E

C

/R Incorporated Providing Environmental Technical Support Since 1989

501 Eastowne Dr., Suite 250  Chapel Hill, North Carolina 27514

Telephone: (919) 484-0222  Fax: (919) 484-0122

MEMORANDUM

TO: Gil Wood, USEPA

David Cole, USEPA

FROM: Jill Mozier, EC/R Inc.

DATE: September 27, 2013

SUBJECT: Notes from September 19, 2013 presentation by Hearthstone, Jotul, and Stove Builder 

International (SBI) to EPA regarding wood stove consumer expectations and likely 

behavior in response to NSPS, and concerns from non-catalytic manufacturers.

Attendees (at EPA, RTP, NC):

EPA Non-Catalytic Manufacturer EC/R

Gil Wood David Kuhfahl, Hearthstone Jill Mozier

Greg Green Marc-Antoine Cantin, SBI

Kimber Scavo Roger Purinton, Jotul

Larry Sorrels

David Cole

Mike Toney

David Kuhfahl from Heathstone led the presentation (“The Future of Wood Heat – 2013 and Beyond”,

attached). He noted that after last year’s trade group his company and others formed an informal group 

which represents ~37% of total non-pellet cordwood industry (manufacturers in this informal group are 

listed in the attached). He further noted that non-catalytic stoves represent 73% of sales, which include 

non-cat cordwood woodstoves and forced air furnaces (this group does not include hydronic heaters 

which they consider part of the problem for the industry).

This informal non-cat cordwood group of manufacturers agree with the NSPS initiative, but wants EPA 

to set “reasonable, real world” emission limits. He noted that industry should do its part, that the real 

efficiency of appliances should be reported. He noted that uncertified stoves emit 5 to 20 times what 

certified stoves do and that this group of manufacturers he’s speaking on behalf of only manufactures 

certified stoves. Part of the problem, according to this group, is that exempt units are imported from 

China for example. These importers don’t report their numbers to HPBA, but there are many of them. 

[Gil Wood noted that EPA is attempting to close this loophole with the proposed NSPS.]

Roger Purinton noted that Jotul is willing to give up making parts for old stoves because it’s the right 

thing to do. He agreed that there are lots of rebuild & replace; that the sale of uncertified stoves needs to 

stop. [Gil noted that while he personally agrees, and hopes EPA will continue to educate consumers, this 

piece is not part of the NSPS regulatory package – it’s not under NSPS’ purview.] Marc-Antoine Cantin 

said that no one should forget that homeowners have a choice, that it’s too easy for consumers to buy 
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uncertified stoves. [Greg Green encouraged the manufacturers to continue to give this message. Gil 

noted there has been some success in Oregon with removal of old stoves when homes are re-sold.] 

Roger noted that Europe has been very successful in getting rid of old, dirty stoves in homes.

David noted that part of the decline in woodstove sales happened after the 1988 NSPS and consumers 

could no longer find stoves for < $200. David further noted that the group does not necessarily see 

catalysts as a good thing. When Greg Green asked what their issue is with catalysts, David noted that 

they have many issues and the presentation will address those.

David said he’d provide a copy of the consumer survey upon which his presentation is based entitled 

“Wood Stove/Fireplace Emissions Study – Impact on Product Replacement & Consumer Opinions 

Supplemental Report – Products Combined” conducted by the Stevenson Company. He presented his 

power point slides (attached to this memo), noting that what consumers are looking for has changed in 

the last 10 years – that is, while price is still the #1 concern, efficiency is now the #2 concern and this 

concern for efficiency was not so important 10 years ago. He also noted that the lower cost steel stove 

market has grown, while the more expensive cast iron stove market has declined due partly to the lower 

natural gas prices. (Gas burning, in his observation, tends to be based on discretionary income, including 

especially burning in decorative gas appliances.)

Roger noted that wood heaters, unlike other appliances, have efficiencies that are significantly impacted 

by human factors. [Gil noted that there are a number of efficiency calculators out there, but they may not 

be providing much payback – it’s unclear to what extent the average consumers are paying attention to 

how to operate their wood heaters.] Roger noted that in his observation the efficiency questions come 

from engineers and the like, not necessarily from the average homeowner. Marc noted that people 

[including manufacturers, labs, countries] measure efficiency differently so that there exists different 

numbers for the same or similar stoves – this is confusing to customers. [Gil noted that the proposed 

NSPS will hopefully clarify the situation of LHV versus HHV, 8-hour burn rates, and CSA B415.10.] 

Roger noted that because he works for Jotul, he’s familiar with the European test method and mentioned 

an example of one European lab in particular that gets amazingly high efficiency numbers. In general, 

Roger has noticed that the efficiencies of European stoves are much lower when tested with nonEuropean test methods and he generally concludes therefore that European technology is not superior to 

North American technology; they are merely using a different test method. Marc agreed, noting that in 

the Czech Republic the efficiency is calculated over one burn rate – the sweet spot essentially – so the 

efficiencies look great – but in North America, manufacturers get penalized by burn rate categories that 

aren’t typical (eg., low burn rates that cause smoldering). Marc later noted that, on the other side of the 

spectrum, in Australia, 60% is a good number since the efficiency has to be calculated over 3 burn rates 

– so Australian efficiencies are lower than Europe or Canada.

David noted that the reason efficiency is now the #2 concern is due largely to internet pre-shopping and 

reading of Alliance for Green Heat articles. David further noted the confusion over the hang tag default 

numbers, which the manufacturers never certified to, the confusion caused by hang tag versus marketing 

brochure numbers, and the confusion caused by combustion efficiency versus thermal efficiency versus 

a hybrid of the two. David concluded that manufacturers have never had an “efficiency pond” to play in, 

so agreed upon test methods and uniform reporting requirements need to be determined. [Gil noted that 

this is EPA’s aim/hope in the draft NSPS proposal.]
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David and Roger noted that some consumers are in principle opposed to pellet stoves because they want 

to be off-grid and don’t want a wood heater that requires electricity.

Regarding the problem with catalytic stoves, David noted that a non-cat stove is designed to pass the 

Washington standards with one easy-to-use air control lever. A cat stove has a minimum of one air 

control lever plus a bypass damper. [Personal anecdote - David owned a cat stove in his home years ago 

and the catalyst never, over many years, engaged properly.] David highlighted that 79% of catalytic 

stove owners do know why the catalyst exists but they still often operate the stove with the damper open 

without the cat engaged – because the stove can smoke if the damper is prematurely closed before 

catalyst “light-off”– so the design isn’t working well for some consumers – therefore there’s no net 

improvement in air quality when that occurs. In the end, the cat stove can be dirtier than the non-cat 

stove when the operator fails to engage the catalyst properly (e.g., may attain 2.5 g/hr with the damper 

closed/engaged on a cat, but when it’s open the emissions are ~21 g/hr). Marc further highlighted that 

for cat stove owners of < 5 years, 63% have replaced the catalyst. (Note: in answer to an earlier 

question, Marc clarified that the consumers who participated in the survey were educated before each 

question – so, for example, they did know what a catalyst was.) David concluded that the average life of 

a catalyst is 5 years – and that after 5 years the lab numbers are 4.5 g/hr for non-cat stoves but ~8.1 g/hr 

for cat stoves. 

Thus the non-cat manufacturers have a concern that people believe catalytic stoves are a panacea, when 

they are not. [Gil noted that the NSPS proposal is getting away from 2 different emission standards for 

cat and non-cat stoves. Manufacturers will be able to figure out how to best get to the emission 

standard.] Marc responded that the difficulty in the non-cat manufacturers figuring it out is that the 

number is low due to catalytic numbers. [Gil noted that some non-cat stoves can already achieve these 

numbers.] Marc continued that the manufacturers will take a short-cut, have a panic reaction, and turn to 

production of catalytic stoves, but this will cause a worse environmental situation (due to issues noted 

above), plus higher prices will drive consumers away from purchasing new stoves and encourage them 

to keep their old stoves. Roger noted that even if given 5 years to get a non-cat stove to achieve lower 

numbers, getting those lower numbers with a cat stove is a sure thing and can occur in 1 year – so 

industry will naturally move in that direction. David noted that cat stoves are hard to operate and that the 

efficiencies according to the Catalytic Hearth Coalition are not necessarily real. David noted that the 

consumer survey revealed that >40% of cat stoves were burned in bypass of the catalyst mode. 

The non-cat manufacturers represented at this meeting concluded that they want the Washington 

Standard (2.5 g/hr for cat stoves; 4.5 g/hr for non-cat stoves) and want the market to force emissions 

down with better technology. David stated that they also want a standardized method for efficiencies, 

but not a regulating efficiency level, so that they could build the dataset. [Gil earlier noted that the draft 

proposal is requiring the reporting of efficiencies, but not setting an efficiency standard.] David further 

noted that manufacturers need 5 years to transition to cordwood. Marc expounded that manufacturers 

can go from crib to cord, or can go to a lower emission number but cannot achieve all of these things at 

once, especially not at the prescribed burn rates, and definitely not at fireboxes > 3 cubic feet. Marc 

later noted that it is unrealistic of WESTAR and NESCAUM to push for 1.3 g/hr and for cordwood and

across all burn rates. David and Roger agreed that they have no idea if they can achieve 4.5 g/hr with 

cordwood. [Gil noted that Rick Curkeet has said cribs are just as variable as cordwood.] Marc said he 
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agrees with Rick’s basic argument which is to design the unit based on how homeowners will actually 

use it. [Gil agreed this is a persuasive argument and wanted labs to replicate real-world home use as 

much as possible.] Marc further suggested that the minimum burn rate with cordwood should be a 

percentage of the maximum burn rate – that a 1 kg/hr burn rate will never work, since a hot start is 

required. SBI opens 25% of air intake, otherwise stove chokes and doesn’t light, especially with dense 

wood. Thus the minimum burn rate “is a killer”, especially for the bigger fireboxes. David concluded 

that the non-cat manufacturers represented would like EPA to consider the minimum burn rate issue, and 

re-iterated that they want market pressure to drive industry. He further noted that anything < 4.5 g/hr is a 

crap shoot and just luck of the draw.

Gil expressed thanks for the data in the survey (which the manufacturers noted cost > $20,000). Gil 

further concluded that EPA is looking at the best systems of emission reduction – that there is lots of 

pressure to get to the truly best performance levels. While only a handful of models and manufacturers 

may be there now, EPA is giving 5 years for everyone to get there. Marc responded that 5 years is not a 

lot of time. He explained that it takes 1 year to get a model under 4.5 g/hr but then his company also 

needs to get 14 other models there. Even the certification testing of so many models is problematic 

because humidity in the air matters, for example. Ben Myren has suggested not testing during high 

humidity – so everyone is choosing labs out west. [Gil assured everyone that this is a proposal, not the 

final rule, and that there will be a public comment period.]

Roger noted that Jotul is transparent and that while BDT is not focussed only on clean air, he frankly 

sees potential for proposed stricter standards to create a safety concern. He noted that he is not yet ready 

to provide data on this, but will first need to confirm his suspicions and then provide information to Gil 

related to this potential safety concern.

In answer to a question from Greg regarding how different are the designs of the 14 models SBI would 

reportedly need to perform R&D on, Mark explained that SBI produces strictly solid fuel heaters (3 

pellet units, 3 fireplace insert firebox designs, and 3 FAF designs). SBI needs 3 fireboxes in each 

application of FAF, fireplaces, and pellet stoves and the company cannot accomplish that for all of these 

models in 5 years. Marc further noted that while the 1.3 g/hr looks sexy on paper, there is no true 

environmental benefit, in his opinion (due to issue of driving industry towards catalytic stoves and 

consumers leaving dampers open on cat stoves, noted above). Marc later expounded that the 14 units use 

the same technology throughout but are “different enough”, and that 1 to 1.5 years per unit are needed 

for R&D at $300,000 per unit/model (steel design). David noted that the costs for cast iron stoves are 

nearly twice that, or ~$600,000 for R&D per model.

Roger noted that the old stoves will be around for another 30 years and that until we get rid of the old 

stoves, there will be no measurable improvement in airshed. [Gil noted that the NSPS will not be an 

immediate fix and that nationwide changeouts could give a bigger health benefit quicker than the NSPS

and that is why EPA has encouraged and is continuing to encourage changeout as quickly as possible.] 

Roger noted that Jotul is doing a “cash for clunkers” program that is quite successful – people can get 

$500 out of the deal. He also noted that there are encouraging units out there – for example, a pressed 

vermiculite stove design that gets very good numbers, but it’s too fragile for in home use – the loading 

of wood cracks the unit.
Wood stove 

manu

facturers asking 

for a common sense 

approach to the future.
Concerning the “Standards of

Performance for New ResidentialW

Heaters, New Residential Hydron

Heaters Heaters and Forced‐Air F rnaces Furnaces, a

New Residential Residential Masonry Masonry Heaters Heaters
Who are we?

 We are a group of manufacturers that make and

distribute distribute free standing standing and built-in EPA Certified Certifiedwood fired products in North America:

 Jtl o u NA SBI HearthStone Pacific Energy Napoleon – Wolf Steel ICC – RSF Regency – FPI

 Together, we represent 37% of the total industry 2012 US

shipments of EPA certified appliances.
NSPS 2013

 EPA states that this proposal “updates the 1988 NSPS to 

reflect significant advancements in wood heater technoloand design, broadens the range of residential wood-heatappliances covered by the regulation, and improves and st li i l t ti d ” treamlines implementation procedures.”

 EPA further states that the rule “is expected to require 

manufacturers to redesign wood heaters to be cleaner anlower emitting” and that these changes would provide for better and more efficient performance.
We agree with the NSPS init

1. EPA is tasked to regulate emissions for wood burning 

appliances

2. EPA should set forward reasonable emissions limits3. The industry must do its part at improving air quality whil

providing wood burning appliances to homeowners for pror supplemental heat 

4. We should be reporting our appliances’ real efficiency5. New, uncertified wood burning appliances should be a th

the past

6. The sale of any used uncertified stoves should be stoppe
What is right to do? We belie

encourasourced

Time near car

heat is bto every

Clean 

Combustion
What is right to do?

 When a tree rots 

naturally or burns, the carbon contained in the woodi l d s release

d

back to the atmosphere. 
How Can We Do It?

We, as manufacturers; want to be able to continue clean woo

d b i urn ng appliances

to all:

 Clean burning heaters, from compact simple stoves fo

smaller budget / need to smaller budget

/ need to larger sophisticated fireplaces 

sophisticated fireplaces 

bigger budgets / need and anything in between

 With or without catal

yst

We, as an industry must: Consider consumer preferences: price, efficiency and 

friendliness

 Always respect EPA regulations
What do we Know?

 We soug py ht out an independent survey firm to 

reveal consumer preferences and help us understand their likely behavior.

 This 15 minute survey conducted in June of 201

This 15 minute survey conducted in June of 201

is the most recent survey conducted in our industry.
Wood Stove/Fireplace Emissions Study

Impact On Product Replacement & Consumer Opinio

7/11/2013
What do We Know?

 610 relevant consumers as a data base:

○ 539 were currently hearth product owners○ 71 were purchase “intenders”

 This significant data set gives us insight into consume

preferences and expectations to help us then understalikely g pp behavior of the general population.

 Sample size precision is estimated at ± 4.0 percentage 

a 95% confidence level. a 95% confidence level.

Note: The survey excluded decorative fireplace owners. It strictly concentrated 

on wood heater owners, g g g, including those using freestanding stoves, built-in stoves,and stoves inserts.
Who Answered our Survey?
Location of the Appliances
Ownership and intent
Purpose and frequency of us
What do consumers care about? 
The #1 Decision Making Reason to 

S l te ec 

a N ew

Wood 

Burni A li ing Appliance is

Price $$

1. The Stevenson Company Survey was clear.

Price $$

2. In 2012 sales, HPBA manufacturer’s data shows an 

overall decline (-23.7%) in higher cost Cast Iron EPA wood stove volume with an average wholesale of $1230, while the lower cost Steel EPA wood stoves with an average wholesale of $752 enjoyed an i f 20 6% increase o

f 20.6%. 
Are Homeowners Likely to Spend 500$ 

Premium for Catal

y gy tic or “New Technology”?
Are Owners more Likely to Fix Their Current Ap

or Find a Used “Previous Technology” Previous Technology” Applianc

Applianc
The #2 Decision Decision Making Reason to Select 

Wood Burning Product is:

Efficiency!

 Currently reported efficiencies are confusing to Currently reported efficiencies are confusing to

consumers;

 Industry needs and supports the idea of a si

standardized method of calculating and repoeffi i c ency.
Natural Draft Appliances and Efficiency

 Our consumers want energy independen

and power free reliability.

 Wood heaters are natural draft appliance

 They continue to work during power failure. They generate thei

r own powe

r to create a

maintain draft.
The #3 Consumer preference is:

User Friendly Controls and Ease of U

 A non catalytic wood stove is designed to pass t

exi ti t i t W hi t St t t d d it

isting stringent Washington State standard wit

one air control lever, “Low to High” with a passivnon-cat secondary y burn system. Easy to use.

 A catalytic wood stove can also be designed to 

pass the existing Washington State standard buhas at minimum one air control lever and a bypadamp pp yp er that needs to be properly operated to buclean.
Catalytic Stove Owners say...
What Happens if a Typical Cat Appliance 

Not O

p py erated Pro

perl

y

?

Open Closed Burned 

Damper

Always with damper open 21% 100% 0% 21% 

Often with damper open 22% 75% 25% 17% 

Sometimes with damper open 29% 50% 50% 15% 

Rarely with damper open 19% 25% 75% 5% 

N ith

d 9% 0% 100% 0% 

21.00 13.00

Never

with

damper open 9% 0% 100% 0% 

Average 57% 

Cat emissions assumption Cat Emissions vs. Non Cat

2.50

Emissions with damper closed

4.5

Overall average emissions for a

Emissions with damper closed typical cat applianceEmissions with damper open

yp pp

Emissions of non‐cat appliance

Assumptions: All appliances have a catalyst in working condition and are at 2.5g/h, as per the current Washington State limit. Cat appliance emissions with the damper open are equivalent to the emissions of an uncertified appliance emissions with the damper open are equivalent to the emissions of an uncertified stove at 21 g/h fro

stove at 21 g/h fro

Reference: (1) Comparison of Particulate Emission Rates from the In-Home Use of Certified Wood Stove Models 

Certification Emission Values and a Comparison with Emissions from Uncertified Wood Stoves, James E. Houck, 
Catalytic stove age and expected 

Maintenance
What Happens if Cat Appliances are Not 

M i i d P l ? M

aintained Properly

?

Yes No Working Not Working Cat Wor

Cat Cat replaced Unreplaced Cat Like

Appliance

<5 yrs 32% 63% 37% 100% 0% 100% 

5‐10 yrs 25% 48% 52% 80% 20% 90% 

10‐20 yrs 15% 42% 58% 20% 80% 54% 

20+yrs 13% 36% 64% 0% 100% 36% 

A 70% 

8.087

4.5

21.00

Average 70% 

Cat Emissions assumption Cat Emissions vs. Non Cat

Overall average emissions fora typical cat applianceEmissions of non‐cat appliance

2.50

Emissions with cat workingEmissions with cat not working

Assumptions: All appliances with a catalyst in working condition and are at 2.5g/h, as per the current Washington State limit. 

Cat appliance emissions with the catalyst not working are equivalent to the emissions of an uncertified stove at 21 g/

Emissions with cat not working Emissions of non cat appliance

Reference: (1) Comparison of Particulate Emission Rates from the In-Home Use of Certified Wood Stove Models wi

Certification Emission Values and a Comparison with Emissions from Uncertified Wood Stoves, James E. Houck, 20
What are dealers saying about

C l i h ? Catalytic heaters

?

 From a dealer web site:



“...Among the disadvantages is that learning to how to the catalyst to get the best efficiency is a bit more tricky a non-catalytic stove, and many manuals for catalytic stare not very helpful helpful. We at Custom Fireplaces Fireplaces

& More 

written our own "Catalytic Woodstove 101" guide, wexplains how to get the best out of the catalyst step by when breaking in a new stove. We also make ourseavailable to answer any questions a new stove owner have. Eventually, the catalyst will have to be replaced....“

From: http://www.customfireplacesandmore.com/hearth-articles/catalytic-non-catalytic.h
Catalytic wood heaters

 The Catal

ytic Hearth Coalition said:

 Regarding Efficiency: “....catalytic stoves are more effi

then their non-catalytic counterparts. As you know, this been recognized for some time as manifested in the defficiencies of 72% for catalyst stoves compared to 63non-catalyst woodstoves in the current NSPS.”

 The default efficiency were derived based on a 

number of appliances 25 years ago. number of appliances 25 years ago. It was an It was anacceptable average back then, probably not verrelevant today. 
Catalytic Combustors

 The Catalytic Hearth Coalition said:

 “A longevity study on two catalytic appliances was performe

concluded that after 9 years those cats were still in working condition.”

 Omni tests on the two cats just confirmed that those two 

are in the average for longevity. 

 Our survey revealed that more than 40% of appliances a

burned always or often on bypass. In fact, these cats may have the equivalent of 4.5 years of usage or no use at all

 By comparison, the Stevenson Company survey interview

total of 610 consumers. Sample size precision is estimat± 4.0 percentage points at a 95% confidence level.
Catalytic Combustors

 The Catalytic Hearth Coalition showed a home heating 

comparison between a Washington 4.5g/h non-cat stove with 75% efficiency and a 1.76g/h cat stove with 82.5% efficiency.

 A t recen

t E l ti va uation 

of Overall Efficiency for EPA Certified Non-catal

ytic Wood 

Heaters showed no correlation between emissions and overall efficiency overall efficiency.

Ferguson, Andors & company, July 2011 
Catalytic Combustors

 Some thoughts: 

 Cat appliances burn without flames. Some people are 

than enthusiastic about the flameless fire. 

 Catalytic stoves work well in a laboratory but it is 

misleading to believe that the air quality will be protectwhen the homeowner has when the homeowner has the very simple choice of no

the very simple choice of no

engaging the catalyst at all, or ignoring maintenance needs.

○ The Stevenson survey revealed over 40% of homeowners 

use their catalytic appliance with the bypass “always” or “often” o

pen.
What do We Want?

 We want the EPA:

 To continue to regulate wood-heater performa

p gg g romul

gatin

g the current Washin

gton emissio

which will have a better impact on the emissioinventory than forcing higher prices and “useru e dy nfrie

n

dly” tec o ogy hn

ology:

2.5 g/h for catalytic appliances 

to offset the risks of not replacing the catalytic comb

and not using the bypass properly

4.5 g/h for non-catalytic appliances
What do We Want?

 We want the EPA:

 To select a standardized method of measurin

and reporting efficiency for wood burning appliances that reflect the way homeowners utheir wood heater.

 To measure and report efficiency, not regulate 
What do We Want?

 We want the EPA:

 To consider realistic minimum burn rates to 

accommodate larger stoves
What do We Want?

 We want the EPA:

 To allow market pressures to direct manufact

to come up with cost effective, use

r-friendly 

technologies to reduce the emissions of their app g y 

liances. EPA needs to reco

gnize that b

y s

the target for non-cat wood heaters at 4.5g/h, manufacturers will end-up with better results.
Simply Clean Combustion
Thank You!